The 3B says the shares were issued under Rule 7.1A (not 7.1, or as shortfall to a rights issue or SPP).
Thus it seems the 20,000,000 shares are just pre-ratified 7.1A shares.
Perhaps the word "shortfall" is referring to the difference between the SPP target capital raising amount and the amount actually raised.
Poor choice of words but I think that's what they mean.
The 3B says the shares were issued under Rule 7.1A (not 7.1, or...
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